Response to consultation on draft guidelines on recovery plans indicators

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Question 2: Do you consider that there are other categories of indicators apart from those reflected in the draft Guidelines which should be included in the minimum list of recovery plan indicators?

ESBG does not believe that further categories would be necessary. However, if in the future the capital regulatory framework includes new elements, such as the minimum requirement for own funds and eligible liabilities (MREL), they could perhaps be included in the list of indicators, provided that they are relevant for the respective institutions.

Question 3: Do you agree with the list of specific recovery plan indicators included in Annex I, Section C, or would you propose to add other indicators to this Section?

In principle ESBG agrees with the list. However, a certain degree of differentiation between categories (binding vs. ancillary indicators), as explained in the response to question 1, could be introduced.

Question 4: Do you consider that these Guidelines should establish the threshold for each quantitative recovery plan indicator to define the point at which the institution may need to take recovery measures to restore its financial position?

ESBG is not in favour of the EBA establishing the precise thresholds for quantitative indicators. We rather believe that each entity should be able to set the thresholds based on its business and risk management model. Therefore, a one-size-fits-all approach for the thresholds is not a workable solution in our opinion.

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Name of organisation

European Savings and Retail Banking Group